Privacy Policy
1) Introduction
This privacy policy explains the ways in which we process your personal data. ‘Personal data’ is defined as all information about an identified or identifiable natural person. In addition, this policy contains information about your privacy rights and our obligations. The privacy policy is divided into the following sections:
- Introduction
- What personal data do we process, for what purposes and on what basis do we do this?
- With whom can we share your personal data?
- How long do we store your personal data?
- How do we protect your personal data?
- What are your privacy rights and how can you exercise them?
- Where can you go if you have a complaint or question about the processing of your personal data?
We reserve the right to change this privacy policy. The most recent version of this privacy policy is available on our website. If there are substantial changes that could significantly affect one or more data subjects, we strive to inform these data subjects directly.
In the performance of our activities we may process personal data. On the basis of applicable data protection legislation - in particular the General Data Protection Regulation (GDPR) - we qualify as controller.
2) What personal data do we process, for what purposes and on what basis do we do this?
Depending on the relationship you have with us, we may process certain personal data.
- If you are a business client, please refer to section 2.1 of this privacy policy.
- If you have ordered a product in our webshop, please refer to section 2.2 of this privacy policy.
- If you have purchased a product in one of our physical stores, please refer to section 2.3 of this privacy policy.
- If you want to apply for a job or have applied for a job with us, please refer to section 2.4 of this privacy policy.
- If you attend one of our events, please refer to section 2.5 of this privacy policy.
- If you visit one of our locations, please refer to section 2.6 of this privacy policy.
- If you visit our website, please refer to section 2.7 of this privacy policy.
- If you email or otherwise contact us, please refer to section 2.8 of this privacy policy.
In these sections we also always indicate why we process these personal data ("purposes") and on what legal basis we base this. We process your personal data on the basis of one or more of the following legal bases:
- when this is necessary for the performance of an agreement to which you are a party or to perform pre-contractual steps at your request;
- when this is necessary to comply with a legal obligation;
- when this is necessary to protect our legitimate interests or the interests of a third party;
- with your consent.
When we process your personal data on the basis of your consent, we will request it separately. You can always withdraw your consent (see also below in section 6) “What are your privacy rights and how can you exercise them?”). We would like to point out that withdrawing your consent does not affect the lawfulness of the processing of your personal data before the withdrawal of your consent.
When processing is based on the basis of 'legitimate interest', this interest is briefly explained. If you have specific questions about this, you can always contact us.
2.1) You are a (business) client
In the context of starting a business relationship and entering into an agreement, we may process the following personal data that we collect directly from you or from public sources (such as the Trade Register and the Chamber of Commerce):
- initials, first and last name, title, gender, signature, address details;
- other contact details, such as telephone number, email address and fax number;
- payment details (including the bank account number), company details, details of the legal representative, details of the Ultimate Beneficial Owner, certain details regarding an identity document, position, extracts from registers (public or not), VAT registration, order information.
Below we indicate for which purposes we process these personal data, with the associated legal bases (a to d as described above):
- to be able to register you, to identify you and to check whether you are authorized to represent our customer (a, b, c: the importance of being able to offer and provide or purchase services);
- to be able to draw up and conclude agreements with you (a, b, c: the importance of being able to offer and provide or purchase services);
- to be able to provide or purchase the agreed services to you (a, b, c: the importance of being able to offer and provide or purchase services);
- to be able to keep a correct administration (a, b, c: the importance of keeping correct administration);
- for billing and payment purposes, including the collection of claims (a, b, c: the importance of being able to keep correct administration and to make / collect payments);
- for the performance of audits and internal controls (a, b, c: the importance of keeping a correct administration);
- to keep in touch and communicate with you (a, b, c: the importance of bringing our services to the attention of existing customers, d);
- to send you our newsletters and to keep you informed about offers (a, b, c: the importance of bringing our services to the attention of existing customers, d);
- to deal with any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
- to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).
2.2) You have ordered a product in our webshop
When you order a product in our webshop, we may process the following personal data that you provide to us:
- initials, first and last name, title, gender, address details;
- other contact details, such as telephone number, e-mail address and fax number;
- payment details (including bank account number), order information.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- to be able to offer and provide the agreed services to you, including creating an account with the option to log in and place an order (a, b, c: the importance of being able to offer services and to provide);
- to be able to draw up and conclude agreements with you (a, b, c: the importance of being able to offer or purchase services);
- to be able to keep correct administration (a, b, c: the importance of keeping correct administration);
- to optimize and personalize your shopping experience (c: the importance of being able to offer you the best possible and personal shopping experience and d);
- to keep in touch and communicate with you (a, b, c: the importance of bringing our services to the attention of existing customers);
- to send you newsletters and to keep you informed of offers (c: the importance of bringing our services to the attention of existing customers, d);
- handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b and c: to defend rights, to maintain and improve existing relationships through proper complaints handling, to improve the quality of the service);
- to comply with our legal obligations (b, c: the importance of being able to comply with these legal obligations).
2.3) You have made a purchase in one of our physical stores
When you buy, return or request a repair from a product in one of our stores, we may process the following personal data that you provide to us:
- initials, first and last name, title, gender, signature, address details;
- other contact details, such as telephone number and email address;
- payment details, order information.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- to be able to offer and provide the agreed services to you (a, b, c);
- to be able to keep correct administration (a, b, c);
- to keep in touch and communicate with you (a, b, c);
- handle any complaints and disputes, including assessing our legal position, defending it and exercising our rights (a, b, c);
- to comply with our legal obligations (b, c).
2.4) You want to apply or have applied for a job
When you apply for a job with us, we may process the following personal data provided to us by you or through third parties (such as an employment or recruitment agency) or obtained by us from other public sources (such as social media):
- initials, first and last name, title, gender, address details;
- other contact details, such as telephone number and email address;
- nationality, date and place of birth;
- availability, CV (possibly with photo) and employment history, training history (copies of diplomas, certificates), motivation letter;
- notes on interviews and written communication with the applicant;
- where relevant for the vacancy: references, screening results, certificate of conduct, certificate of no objection.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- recruitment and selection (a, b, c, d);
- to keep in touch and communicate with you (a, b, c);
- to comply with agreements with employment and secondment agencies (a, b, c);
- internal control and company security (c);
- improvement of the application procedure (c);
- handling questions, comments and complaints (a, b);
- to comply with our legal obligations (b, c).
2.5) You attend one of our events
Depending on the type of event, we may process the following personal data provided by you or created by us:
- initials, first and last name, title, gender, address;
- other contact details, such as telephone number and email address;
- date and place of birth;
- CV (possibly with photo) and employment history, motivation letter;
- photo and video footage of the event.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- to provide access to locations and maintain correct access administration (a, b, c);
- to make payments possible (a, b, c);
- to keep in touch and communicate with you (a, b, c);
- recruitment and selection (a, b, c, d);
- internal control and company security (c);
- for marketing and promotional purposes (c, d);
- handling questions, comments and complaints (a, b);
- to comply with our legal obligations (b, c).
2.6) You visit one of our locations
When you visit one of our locations, we may process the following personal data, which we obtain directly from you or through third parties (such as security services):
- initials, first and last name, name of organization, contact person;
- email address, telephone number;
- identity document number, signature;
- date, arrival and departure time;
- CCTV footage;
- license plate.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- to provide access to locations and maintain correct access administration (a, b, c);
- the security of locations, properties and employees (b, c);
- to investigate and handle incidents and irregularities (b, c);
- handle any complaints and disputes (a, b, c);
- to comply with our legal obligations (b, c).
2.7) You visit our website
When you visit our website, we may process the following personal data:
- data related to the operating system, the browser used, IP address;
- data relating to the unique identifiers associated with the device used;
- data relating to the web pages consulted;
- data relating to products viewed online (including products searched, viewed, purchased or added to cart);
- data relating to time spent on certain parts of the site or an interface site or application, including the date and time of the visit.
Below we indicate for which purposes we process this personal data, with the associated legal bases (a to d as described above):
- to optimize and personalize your shopping experience (c, d);
- to personalize your shopping experience based on your account information and search, browsing and purchase history (c, d);
- to send you personalized advertisements (c, d);
- to perform generic analyses relating to visitor's behavior (c);
- to send newsletters and keep you informed about offers (c, d);
- to handle any complaints and disputes (a, b, c);
- to comply with legal obligations (b, c).
We may process this personal data through the use of cookies and similar techniques. Cookies are small text files that are placed in your browser when a website is visited. Cookies can process personal data. For more information, please read our cookie policy.
3) With whom can we share your personal data?
We do not provide your personal data to third parties ("recipients"), unless necessary for the purposes described, when legally required, or with your permission. Third parties must treat your data confidentially and processors must have an agreement that meets legal requirements.
We may share your data with:
- our employees (need-to-know basis);
- entities affiliated with us;
- suppliers (software, couriers, accountants, law/notary offices, etc.);
- courts and government institutions;
- other parties such as regulators if required by law or with your consent.
If we go bankrupt, your data can be shared with the appointed trustee.
We may transfer data outside the EU with adequate legal safeguards, including model contracts approved by the European Commission.
4) How long do we store your personal data?
We do not store personal data longer than necessary. Specific retention periods:
- Job application data: up to four weeks; with permission, up to one year.
- Tax-related data: according to fiscal retention obligations.
- CCTV footage: automatically overwritten after 30 days.
Retention periods can be extended if legal obligations or incidents/disputes require it.
5) How do we protect your personal data?
We use technical, organizational, and administrative measures including firewalls, passwords, limited access, and a security policy. For questions, contact:
6) What are your privacy rights and how can you exercise them?
You have the following rights:
- right to clear information;
- right to access your personal data;
- right to rectification;
- right to erasure (“right to be forgotten”);
- right to restrict processing;
- right to data portability;
- right to object to processing;
- right to withdraw consent where applicable.
No automated decision-making is used (Art. 22 GDPR).
To exercise your rights: [email protected]
We may request additional info to verify identity. Requests are answered within 1 month, extendable by 2 months for complex requests. Refusals are explained. More info: Dutch Data Protection Authority or your national authority.
7) Where can you go if you have a complaint or question about the processing of your personal data?
If a complaint cannot be resolved with us, you can file it with the competent supervisory authority (Dutch Data Protection Authority in the Netherlands, or your local EU authority).
For questions about privacy rights, this policy, or data processing, contact: [email protected]
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